Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No 1 13 “Objective 1e” – High Quality Change resisting to refusing change words Design 2 13 Objective 2, 2nd para Possible conflict with Corporate Plan which states that UDC will UDC to clarify this point oppose 2nd runway but this paragraph wishes to provide employment growth opportunities at Stansted 3 16 Policy SP1, 3rd para Currently states that where no policy, permission will be granted Amend to “where no policy, Council will determine one in order for the application to be determined” 4 19 3.13 Needs to reference inclusion of Garden Communities within the To add “and in alignment and accordance Corporate Plan with UDC’s Corporate Plan” 5 21 Table 3.3 Type B Villages There appears to be some disparity in relation to Wendons Ambo Could there be further development at not being allocated any additional housing or development but Wendons Ambo – seek clarity from UDC we note its proximity to Newport and existing rail links. We also note that the same disparity applies to Ugley, and seek to Where is the evidence to discount Wendons understand and rationalise this decision. Ambo from the proposed site allocations?
Quendon is identified as a site with ‘non strategic housing’ on the Clarify additional road link proposition spatial strategy map, however is included within Ricklings with a along the M11 (old A11) corridor. total of 50 dwellings, this clearly crosses the M11 corridor and Thaxted wishes to seek clarity and understand as to why the Query why Ugley appears to have been opportunities which are clearly present along the old A11 overlooked in terms of development, when corridor are not being fully considered. ideally situated- seek clarity from UDC
A new motorway junction between Chesterford and Stansted (i.e. around the Quendon/Rickley point) would be visually an obvious consideration, therefore making development in these areas more accessible and attractive. This point has been previously raised with no feedback from UDC as to why this is being overlooked. Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 1 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No
6 22 Policy SP2 First line of policy notes that “the majority of development will This should be amended so that there is no be focussed at the towns of Saffron Walden and Great Dunmow assumption of hierarchy for development in etc etc…” SW and should state “the majority of development will be at the new Garden Communities at Easton Park, West Braintree and North Uttlesford followed by development at the towns of Saffron Walden and Great Dunmow” this changes the hierarchy of proposed development 7 26 3.42 The housing figure for Uttlesford is 14,100 of a total 46,058 across Query this allocation with UDC, why 30% of 4 authorities. 14,100 is more than ¼ of the total requirement and housing for Uttlesford? represents 30% of the requirement across 4 authorities. It is the opinion of Thaxted Parish Council that Uttlesford must If this percentage is based on actual and re-visit their Objectively Assessed Housing Need figures. The projected population figures from census, is figures that they are currently using are now out of date and it fair to assume that because there has probably hugely inflated giving rise to a requirement for far more been a large percentage increase in past 10 housing than is actually needed. Since their figures were years that this should continue? This should produced we have had Brexit (and the latest net migration figures be re considered to reflect a more accurate which are a fraction of what they were pre-Brexit); the second statement of needs. runway for Heathrow; and an analysis of Stansted Airport jobs showing that workers don’t actually live in Uttlesford and anticipated growth has been over-stated. 8 31 3.55 Garden Communities Should cross reference to UDC’s Corporate Plan to further Add cross reference in Local Plan to support this Corporate Plan 9 34 Policy SP6 Community provisions should also include land, sports facilities This should be included in same paragraph and pavilions. 3 of Policy 10 35 3.61 Should this not state what these strategic highway improvements Add details of the strategic highway should be? improvements
Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 2 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No 11 36 Policy SP7 (point 1) This state’s 5000 homes but on page 35 paragraph 3.61 notes UDC to clarify this point restrictions to 3,300, this is contradictory? 12 36 Policy 7 (point 4) Transport Choice, how will this be achieved? Policy should include some mitigation for increased traffic in/out of SW & Dunmow What preventative measures will be put in place to reduce or and its surrounding rural villages and towns. mitigate against increased traffic flow from development from the rural footprint connecting Dunmow or the newly proposed little Easton garden village through to Thaxted? 13 36 Policy SP7 (point 5) Access strategy, refers to northbound traffic but what about There needs to be contributions towards southbound traffic? This directly relates to the over-use of the capacity improvements in Saffron Walden B184 and its lack of provisions to host additional traffic flow and Southbound traffic too (ie cutting cross between the proposed Little Easton Garden village and its country to Stansted/Thaxted/Gt Dunmow neighbouring villages and towns travelling towards both and beyond) Cambridge and Saffron Walden. 14 38 Policy SP8 (point 4) Transport Choice, seems somewhat limited to Dunmow and There is a lack of public transport options Braintree only. Why is this? between West and North which will need addressing to align the community’s What provisions are being made to join the West Braintree opportunities in terms of employment and Garden community to the surrounding neighbouring networks pubic accessibility. and growing communities? 15 47 Policy SP11 London Stansted Airport development- Notes the proposed development will be Policy potentially against Corporate Plan? Airport assessed against the Local Plan but UDC’S Corporate Plan says it will oppose a 2nd runway at Stansted.
16 47 Policy SP11 This should make provisions to ban night time flights and with no Policy to be amended, and consideration to increase in permitted flightpaths. the statement be investigated with a view to create a more competitive solution to the The statement ‘on airport parking help to protect residential end user. amenity’ is not necessarily factual, the current levy placed on the users of Stansted airport in relation to car park charges needs to be re considered as is it commonly cheaper to take a taxi Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 3 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No therefore local resident are often plagued with cars on streets, near bus stops, or in local rural residential car parks. 17 51 Policy SP12 (point 2) What does UDC consider `Previously Developed Land’? and what Define previously developed land and the is meant by ‘Under-Used?’ criteria for Under-used land, is this suggesting compulsory purchase orders will be implemented by UDC? 18 51 Policy SP12 Development should not take place in any areas rated higher than Proposed new bullet point “Development “low risk” should not take place in any areas rated higher than low risk flooding” 19 52 Housing 4.2 Query greatest need is for 3 or 4 bedroom houses, this is Query this statement from the SHMA and contradicted on page 54 under Housing Mix 4.10 where it is the statement under Housing Mix 4.10 stated ‘whilst the greatest need for affordable housing units is for 2 and 3 bedroom houses’. In addition to this, the work of the emerging Thaxted Neighbourhood plan is contradictory to this and suggests that the need is for 1 or 2-bedroom affordable homes. 20 52 Housing 4.3 Addition – ‘Necessarily require or qualify for subsidised Add in addition in 5th line of paragraph affordable housing’ In addition to this point we should draw back Query and Consider the strategy for to page 30 Provision of jobs and employment 3.52 ‘where non- smaller/ affordable housing B use class employment will form the majority’ 21 54 Housing Policy H1 This should state as led by local demand and outlined in the Amend and add in the addition emerging Neighbourhood Plan and according to the character of the area. 22 54 4.10 Add in ‘Market’ affordable to note those who need 2 & 3 Amend wording as proposed bedroom houses but do not qualify for ‘affordable housing’
23 55 Policy H2 Housing Mix Remove the wording ‘ Majority of the need to market Housing is Amend wording as proposed for 3 & 4+ bedroom market houses’
This should also say 2 & 3 bedroom Market affordable housing
Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 4 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No There is no provision for families wanting market affordable housing who do not qualify for affordable housing.
24 56 Policy H3 This should state sub-division of a flat/ property will not be Amend wording as proposed allowed where the dwelling is in a flood risk area and the flat is created with no access to a 1st floor level for refuge.
25 57 Policy H4 This should include that the applicant must state why the Amend wording as proposed proposed footprint is larger than the existing footprint.
26 58 Policy H5 (point b) Please define ‘unreasonably small’. This should state that garden Amend wording and refer to Essex Design sizes must comply with Essex Design Guide. Essex Design guide Guide requires a garden of 100sqm for a 3 bed houses and no more than 2/5 of the garden in shade on 21 March
27 60 Policy H6 2nd paragraph –add in ‘with reference to the Neighbourhood Plan’ Suggest policy is revised to say;
28 67 Employment 5.3 (point 3) This statement is the ‘Aim’ as laid out in the development What is tangible? how is this to be achieved strategy relating to Thaxted. It is detailed on page 12 of the in a market town with diminishing industry strategy under the heading ‘Town Centres’ and agricultural land being utilised for new homes. 29 87 Policy RET5 To add ‘Appropriate footpaths/cycle paths are provided by Support policy with amended wording as developers/applicant to access facility’ proposed
30 88 7.5 Notes that Low bus use and services are challenging- then the Additional policies required to make public Local Plan should include some incentives to make use of public transport more attractive and viable transport more attractive, viable and affordable. 31 89 7.6 Thaxted would welcome implementations of the cycling strategy Include in plan and would support the exploration of a cycle path between Thaxted and Saffron Walden
Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 5 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No 32 90 7.12 Not only improve existing services but add to the provisions Amend wording where possible to encourage use of public transport. 33 93 Policy TA1 Define what is meant by severe congestion? Also to note; back to Opportunity for NP to go into more detail in inconsistency see point 16 terms of appropriate surfaces, fencing, lighting etc. Shared ROWs should be 2 m wide 34 96 Policy TA3 Support but request that a higher percentage of charging points Amend policy to allow greater provision of are installed. charging points 35 97 Policy TA4 To add ‘and/or any policy as identified within the local Amend policy as proposed Neighbourhood Plans’ The local NP should be able to determine these based on parking issues and levels of car ownership. Development Management should not allow discounting. 36 99 TA5 No Mention of the road link between Dunmow and Cambridge, UDC to respond and consider suggested those using the already over capacity B184 will flood rural points re weight limits. communities. What will be done to mitigate this? There could be some consideration to weight limits of vehicles using this route, in particular to prevent construction traffic using the Thaxted route. Please see our additional point under the heading ‘Land east of the mead – Thaxted’ 37 102 8.7 Is this factually correct. Only 3 public gardens in Uttlesford? Query this 38 102 8.12 Should define ‘Local community’ also as town/parish council and Amend Neighbourhood Plan team.
39 104 Policy INF2 But note the protection of allotment land under 1904 allotment Amend policy as proposed and note query act. Each Parish Council has a DUTY to make provisions for re allotment land. And in addition, consider allotments. Using standards set by Fields in Trust and Natural England in relation to Green Space
40 107 Policy INF3 The limit of 50 means that smaller settlements like those in rural Consider reduction communities such as Thaxted make no contribution.
Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 6 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No 41 113 Policy D2 Support this but the policy should also include that rear Amend as proposed Courtyards should be avoided. 42 114 9.10 Define ‘Large scale development’ UDC to define
43 114 9.14 Add to this paragraph: Amend as proposed ‘Particular regard and consideration must be afforded to the delivery of local community or shopping centres and school provision. Early delivery of these facilities will ensure provisions for the 1st / 2nd cohort of residents’ 44 115 Policy D4 2nd Bullet point – Amend as proposed Add to this policy – ‘and community facilities’
Also add regarding phasing of works to ensure community provision is supplied to the first cohort of residents. 45 116 9.19 Amend to: All major developments will be subject to design Amend as proposed review 46 116 Policy D5 Add to policy: Amend as proposed ‘Design will be in accordance with any specific requirements laid out in the adopted in the Neighbourhood Plan, and will complement the area as identified within the Heritage and character assessment’ 47 117 9.23 Include after final sentence, ‘however, the plot owner must consider that the design will be in accordance with any specific requirements laid out in the adopted Neighbourhood Plan, and will complement the area as identified within the Heritage and charter assessment’ 48 117 Policy D7 How is this land to be identified for self-build? UDC to Clarify land identification policy
Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 7 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No 49 118 Policy D8 Needs to be more specific around provision of waste areas for Amend policy to include additional re waste flats to ensure they are accessible by both residents and refuse access lorries.
50 120 Policy D9 Should add ‘Houses with roof solar panels and water recycling Suggest inclusion schemes will be encouraged’ 51 122 10.5 Amend after town and village design statements: in addition, Amend as proposed some who have emerging or adopted Neighbourhood Plans. 53 123 PolicyEN1 Should there also be a cross reference here to the local listing Query with UDC within the conservation area appraisals? 54 124 Policy EN2 Define ‘substantial pollution’ UDC to clarify 55 126 Policy EN4 Should there be a reference here to locally listed buildings under Query with UDC the conservation area appraisal? 56 127 Policy EN5 Archaeological finds need to remain as an asset and integrated Reconsider the design to compliment the into the landscape as an attraction / monument of local interest archaeological find e.g glass pavement and contribute to the public realm. coverings. Also note Typo first paragraph line 4 final word reads FORT, should be ‘for the develop….’ 57 128 Policy EN6 No this should say NO development should be permitted Amend policy 58 130 Policy EN9 Should this policy also reference the creation of additional parks Amend policy to include new parks and & sites? It currently only seeks to protect the existing rather than sites. create any new space. 59 132 Policy EN10 This policy should also seek to increase existing traditional open Amend policy space and trees. Provision should therefore be made to encourage new creation of these. 60 132 10.34 Support this favour that all development should be located in areas at low risk of flooding. As per amendment suggested in EN11
Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 8 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No 61 134 Policy EN11 Add the word ‘Any’ to paragraph 4 ‘and for any development in Amend policy flood zones’
Add ‘Development in flood zones 3(a) and 3(b) will only be considered where all other sites and opportunities have been exhausted and in exceptional circumstances’ 62 135 Policy EN12 Must include carparks. Amend policy to include car parks and make Possible to have a preference on surface area material, i.e. –not provision for other surface materials. tarmac, but some sort of wet/pour or porous material? 63 137 Policy EN13 Should include some reference here to sustainable water supply? Amend policy E.g. – ‘Development which incorporates water recycling (i.e. rain water used for toilet facilities) will be considered favourably’
64 140 Policy EN16 How to measure or mitigate against this? Policy should be amended to include provision for the measuring or mitigation of How to prove that the development has contributed to any this and also make reference to the impact worsening pollution? of new development
65 142 Policy EN18 To include: All activity should comply with BS 5228:2009 Code of Amend as proposed. Practice for noise and vibration control on construction and open sites. 66 146 Policy C2 Is this a simple typo at the end of the policy? Query with UDC Should this last bullet point be deleted? 67 269 Land east of the mead - This site was included in the ‘Call for sites’ ref 17Tha15 which was Clarity as to why this site is included at all, Thaxted subsequently withdrawn from the local plan, speculation as to TPC suggest its complete removal from the the use of the site requires further clarification. In addition to this local plan. the site holds significant environmental interests and has the The conclusions of the neighbourhood plan potential to host an ecological significance to species such as process are that this site is not a preferred newts, bats and rare orchids. It was therefore rejected for location for housing and that there are consideration by both Thaxted Parish council and UDC. other better located sites (principally the Three points are to be considered: Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 9 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No 1) the wildlife habitat former Claypits Farm buildings off Bardfield 2) the Heritage setting and Road). 3) Road Access. 1) habitat. Following the development of neighbouring land off Sampford Road and on the Wedow Road extension, many species have migrated to this site. A report on wildlife and habitats has been prepared involving representatives of the Essex Biodiversity Team from Essex Wildlife Trust and The Essex Reptile and amphibian Club. This report discovered that this site is host to one of the largest colonies on lizards in Essex, together with slow worms and grass snakes and 3 species of bats. With the site now surrounded by new housing development or fully cultivated land this has become the only remaining area of wild habitat. It is rich in many species of both flora and fauna and there is no prospect of off-setting what would be lost through development, onto any other nearby site. A particularly valuable habitat rich in wildlife would therefore be lost if this site was to be developed. 2) the Heritage setting. Concerns as to the view which would be compromised in particular the grade 1 listed Church of St. John the Baptist, the views across the Samford road of the church tower and Spire are of immense importance Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 10 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No and significant relevance to Thaxted as identified in the Neighbourhood Plan. 3) Road Access. There is no road access in relation to this site and all option of creating one would appear to be unsatisfactory. In addition to this the networking roads are already congested, thus driving traffic of varying weights directly through Thaxted when travelling in the direction of Saffron Walden or Cambridge by way of seeking an alternative route or short cut form the A120 and M11 links.
The Thaxted Neighbourhood Plan Chairman has prepared a comprehensive alternative to the road access issues which has been sent to UDC Planning Policy team under separate cover. 68 n/a Claypits farm site The site identified in the ‘Call for Sites’ report 2016, knows as UDC to clarify the inclusion or omission of ‘Claypits farm’ is not included within the local plan, whereby this this site. was identified as a more viable option than the site knows as’ land east of the mead’ which has been included. This was submitted and accepted under the call for sites ref 14Tha15. 69 290 Policy M1, 2nd point Should state “rolling 5 year land supply” Amend policy as proposed
70 290 Policy M1, point b amend “for the market towns and key villages AND (not OR) Amend policy as proposed additional support for Neighbourhood Plans ….” 71 299 Glossary Definition of “Neighbourhood Plan” should be included within Add “Neighbourhood Plan” to glossary the glossary
Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 11 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No 72 310 Objective 1a / target box States 100 affordable homes pa but this is insufficient build to Review and amend target as those set do meet the requirements of the Local Plan. not meet requirements of the Local Plan
14,100 homes required of which 40% are affordable = 5640 affordable homes
5640 divided by 22 years (of the Local Plan) = 256 homes required pa 73 313 Target Box Do these targets for provision of allotments, sports pitches and Query to Sport England standard. If not, public open space meet Sport England standards? they should be
74 317 Reduction in levels of air What will be the frequency and publication of this information? Should be issued at defined time and at pollution least annually 75 320 Appendix 4, point 3 “A suitable body will need to be established” this infers that this Please clarify this point will be a body separate to UDC.
76 322 Point 9 (19.2) Add “or better connectivity is developed as part of the Garden Amend as proposed City principle and infrastructure development”
77 - General Comment There does not appear to be an additional provision within the UDC to advise Local Plan for cemetery / burial ground. Would any be required within the Local Plan period and if yes, any proposed sites?
There is also no reference to the planning permission granted for the crematorium at Great Chesterford and is this a material consideration for any of the policies? 78 - General Comment The Plan should cross-reference to CIL to cover an eventuality To insert (and or CIL) after each reference where UDC may adopt CIL (rather than S106 agreements) to S106 agreements within the document and to also include CIL within the glossary
Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 12 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No 79 - General Comment In relation to the additional air traffic generated by Stansted airport, and the additional road traffic by way of its increased services. Thaxted Parish Council feel that Special attention should be paid to vulnerable groups of the population in sensitive buildings or areas, for instance, in schools and hospitals close to the airport (Thaxted being one of these such areas) and under flight paths. listed building of significant heritage importance should be granted compensation in order to facility repairs from increased pollution and air traffic vibration. Noise assessments should be undertaken on a 24-hour basis so that cumulative impacts can be assessed in built up areas where towns and villages are directly affected, not on the fringe of rural communities where building vibration has little or no impact.
In addition to the above proposed comments, changes action and queries, Thaxted Parish Council would also like to submit their support to the following policies found and contained within the Local Plan.
Ref No Page Policy No / Paragraph Comment Proposed Change / action / Query No 80 77 Policy EMP 2 To be commended Support policy 81 78 Policy EMP3 To be commended Support policy 82 83 Policy RET1 Supported Support Policy 83 93 Policy TA1 Support this policy 84 94 Policy TA2 Support this policy 85 109 Policy INF4 Broadly support 86 110 9.3 Support UDC’s adoption of the Design companion for planning & place making.
Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 13 of 14
Thaxted Parish Council – UDC Local Plan Response – August 2017
87 111 9.7 Support these principles 88 112 Policy D1 Broadly support Support the inclusion of DCLG space standards 89 113 Policy D3 Support this policy 90 116 Policy D6 Support but delete the last sentence – it is unenforceable and Amend as proposed unmanageable 91 117 Policy D7 Support this policy 92 118 9.29 Support this 93 119 9.30 Support this 94 120 Policy D9 Support this 95 121 Policy D10 Support this 96 122 10.3 Support this it seeks to protect historic buildings and fabric. 97 123 10.8 Support this inclusion 98 124 Policy EN2 Support this especially that outline applications in a conservation Define ‘substantial pollution’ area will not be considered. 99 124 Policy EN3 Welcome and support this policy 100 125 10.11 Support return to original characteristics 101 129 Policy EN7 Support this 102 129 Policy EN8 Support this Is there a typo in this? The Last paragraph quotes NE1 but should this be EN1? 103 141 Policy EN17 Broadly support this policy 104 143 Policy EN19 Broadly support this policy 105 145 Policy C1 Support this policy especially the protection of the panoramic views (2nd bullet point) 106 147 Policy C4 Support this policy 107 293 Policy M2 Support policy 108 293 14.22 Support statement. 109 322 Point 4 Welcome and support this
Response from Thaxted Parish Council to UDC’s Local Plan, August 2017 Page 14 of 14